Getting Started with Established Cybersecurity Standards

This article is intended as information only. Please don't consider it legal advice. ABA Compliance Solutions doesn't provide legal services. While we strive to offer accurate and up-to-date information, we always suggest consulting with an attorney for advice tailored to your specific needs.

As an ABA healthcare provider, your primary focus is on delivering top-notch care to your clients. However, in today’s digital age, safeguarding the sensitive information you handle is just as crucial. Cybersecurity isn’t just an IT issue—it’s a vital component of your practice, ensuring that the data you maintain on your clients, your employees, and your business remains safe and secure, and your business stays compliant with regulations. Let’s dive into why cybersecurity matters and how adopting the Health Industry Cybersecurity Practices (HICP) recommended by the 405(d) working group can protect your organization.

Why Cybersecurity is Essential for ABA Healthcare Providers

In the ABA field, you manage a wealth of sensitive client data, including personal health information (PHI), billing details, and treatment plans. You also probably maintain quite a bit of sensitive data about your employees and your business itself. These data are prime targets for cybercriminals. A breach may not only compromise your clients’ privacy, your employees’ privacy, but may also put your organization at risk of significant legal and financial repercussions. Compliance with state regulations and federal regulations such as HIPAA (the Health Insurance Portability and Accountability Act of 1996) isn’t optional—it’s a requirement, and robust cybersecurity measures are one key to meeting these standards.

Why Using Standards to Evaluate Your ABA Company’s Cybersecurity Program Is So Helpful

Using cybersecurity standards like the Health Industry Cybersecurity Practices (HICP) recommended by the 405(d) group to evaluate your security program is crucial. These standards provide a solid framework to protect sensitive client data and ensure compliance with regulations like HIPAA. By adopting and documenting that your company is using the practices advocated by the standards, you not only reduce the risk that your ABA company will experience a significant cybersecurity incident, but implementing and documenting your company’s use of recognized security standards can mitigate potential negative findings during regulatory audits,by showing that your organization is proactively managing cybersecurity risks.

What Are the Health Industry Cybersecurity Practices (HICP)?

The Health Industry Cybersecurity Practices (HICP) were developed by the 405(d) working group, a collaborative effort between the U.S. Department of Health and Human Services (HHS) and industry experts. These practices are designed specifically to help healthcare organizations, including ABA providers, manage and mitigate cybersecurity threats and all of the standards are organized so that they apply to organizations of all sizes, from very small practices, to very large companies.

The HICP outlines ten critically important cybersecurity practices, focusing on five key threats:

• Email Phishing Attacks

• Ransomware Attacks

• Loss or Theft of Equipment or Data

• Insider, Accidental or Malicious Data Loss

• Attacks Against Connected Medical Devices

Why Each Cybersecurity Threat Area Matters

• Email Phishing Attacks:

  • Phishing is one of the most common cyber threats. These attacks trick your employees into revealing sensitive information or installing malicious software. By training your team to recognize phishing attempts, you can significantly reduce the risk of a breach.

• Ransomware Attacks:

  • Ransomware locks your data until a ransom is paid. Implementing regular data backups and maintaining strong cybersecurity defenses can help protect your organization from these devastating attacks.

• Loss or Theft of Equipment or Data:

  • Mobile devices and laptops are convenient but can easily be lost or stolen, putting sensitive data at risk. Encrypting data and using secure access controls are essential practices to prevent unauthorized access.

• Insider, Accidental or Malicious Data Loss:

  • Sometimes, the threat comes from within. Whether accidental or intentional, insider threats can lead to data breaches. By setting up strict access controls and monitoring systems, you can minimize these risks.

• Attacks Against Connected Medical Devices:

  • As ABA providers increasingly use connected devices, the risk of cyber attacks grows. Ensuring that these devices are secure and regularly updated is critical to protecting your clients’ data.

How the HICP Benefits Small and Medium-Sized ABA Organizations

For small- and medium-sized ABA organizations, implementing the HICP can seem like a daunting task. However, at ABA Compliance Solutions we’re here to help you navigate this process. The HICP provides tailored recommendations based on the size of your organization, ensuring that you can adopt cybersecurity practices that are both effective and manageable.

By following the HICP guidelines, you not only enhance your organization’s cybersecurity posture but also ensure compliance with regulatory requirements like HIPAA. This proactive approach reduces the risk of data breaches, helps avoid costly penalties, and builds trust with your clients by demonstrating your commitment to protecting their information.

ABA Compliance Solution’s Recommendations for Getting Started with the HICP Recommended Security Practices

At ABA Compliance Solutions, we understand the unique challenges faced by ABA healthcare providers. We’re here to guide you through the process of implementing and documenting your company’s adoption of the HICP, by providing you the tools and support you need to strengthen your company’s cybersecurity defenses.

To help you get started with adopting the HICP recommended security practices, we here at ABA Compliance Solutions recommend that you:

1. Download the Cybersecurity Practices for Small Healthcare Organizations and review them with key stakeholders in your organization, including company leadership and representatives from your clinical and administrative staff who handle patient, employee, or sensitive company data daily, as they can offer practical insights into security practices.

2. Using the Cybersecurity Practices for Small Healthcare Organizations as a guide, evaluate how you’re currently doing related to each recommendation. You can create your own evaluation tool based on the recommended cybersecurity practices, or our Compliance Connect members can use the customizable tool we’ve developed.

3. Once you’ve assessed where your organization is now relative to each recommended cybersecurity practice, generate a working plan for the steps you’ll take to improve, expand, or more fully adopt each recommended cybersecurity practice. Remember to focus first on the recommended cybersecurity practices that are most important to protecting the data you need to protect, and don’t forget to factor in things like ease of implementation, cost of implementation, and cost of monitoring whether each practice continues to be implemented.

4. Design a system for monitoring and documenting on a monthly or quarterly basis how your company and employees are adhering to each recommended cybersecurity practice. This is important not only so that you know what’s happening in your company’s cybersecurity program, but documenting on a regular basis will also help regulators see that you take cybersecurity seriously.

5. Set a date (usually 6 months or 12 months from your original assessment) for when you’ll evaluate again your cybersecurity practices against the list of Cybersecurity Practices for Small Healthcare Organizations so you can see how your cybersecurity program is maturing.

6. Once your comfortable that your organization has fully adopted each of the each recommended cybersecurity practice in the Cybersecurity Practices for Small Healthcare Organizations, go ahead and review the Cybersecurity Practices for Medium and Large Healthcare Organizations (that’s the second volume iin the HICP series) and start the whole process of assessing and improving your company’s cybersecurity practices against the higher standards set in volume two.

Taking steps now to improve your cybersecurity not only helps protect your clients but also ensures that your organization meets its regulatory obligations. Let’s work together to keep your practice safe and secure. As always, we’re here to help if you need us. Don’t hesitate to reach out.